Clarification on the Energy Company Obligation 4 and the Great British Insulation Scheme: mid-scheme changes government response (published 10 June 2025)
Updated 12 June 2025
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We are clarifying two points stated in the Energy Company Obligation 4 (ECO4) and Great British Insulation Scheme (GBIS) mid-scheme changes government response.
1. GBIS annual targets
The government response document stated: “To further simplify GBIS we will remove its annual targets.”
Upon subsequent consideration, annual targets will remain on GBIS. Removing annual targets on GBIS would not achieve the intended benefit of supporting delivery in relation to previous phases of GBIS. Because of the operation of the GBIS phases, any participant who did not meet their GBIS phase A or B targets at the time cannot subsequently meet these targets following the closure of the relevant GBIS phase. Therefore, to encourage further delivery under GBIS going forward, delivery that a participant reassigns from ECO4 to GBIS will count towards its total home-heating cost reduction obligation and total low-income minimum requirement under GBIS, rather than counting towards a specific GBIS phase or phases.
A participant must still meet their GBIS total home-heating cost reduction obligation by delivering GBIS measures or reassigning delivery from ECO4.
2. Rural area definition
The government response document stated that the rural area definition would be updated, and the check on whether a property is in a rural area would be based on the date when “a project has been completed and notified to Ofgem”.
Notifying measures and projects as formally notified and completed is different under the ECO4 and GBIS legislation. Because of this, and following further consideration, we have clarified the point in time at which a property is checked against the rural area data set. In relation to ECO4, the amendment applies to a measure where Ofgem is first notified, in writing, of the ECO4 project of which the measure forms part on or after the day on which the amending Order comes into force. In relation to GBIS, the amendment applies in relation to a measure where Ofgem is formally notified in accordance with article 25 of the 2023 Order of the measure on or after the day on which the amending Order comes into force.
This aligns with existing Ofgem processes and therefore minimises disruption for participants and Ofgem.